On July 23, 2014, the New York State Department of Financial Services (the “NYDFS”) proposed a regulatory framework for persons that engage in virtual currency activities involving New York (the "BitLicense Proposal"). [1]In doing so, New York has become the first state to propose tailored rules for virtual currency businesses.[2] Comments on the BitLicense Proposal must be submitted to the NYDFS by or on September 6, 2014.